Free Motion for Extension of Time - District Court of Colorado - Colorado

Case 1:03-cv-01973-PSF-MJW

Document 188

Filed 11/23/2005

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 03-CV-1973-PSF-MJW (Consolidated with 04-CV-02112-PSF-MJW) THE WALKER GROUP, INC., Plaintiff, v. FIRST LAYER COMMUNICATIONS, INC. and J.E.H. KNUTSON, Defendants.

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME

Plaintiff Walker Group, Inc., ("Walker Group"), through counsel, and pursuant to Rule 6(b) of the Federal Rules of Civil Procedure respectfully moves the Court for an extension of time of seven (7) days within which to file its application for attorneys' fees and costs. In support of this Motion, Walker Group shows as follows: 1. Final Judgment in this matter was entered on November 14, 2005. Consequently,

Walker Group's application currently is due November 28, 2005. 2. Counsel for Walker Group have plans to be out of the office and out of town for

the Thanksgiving holiday. 3. Walker Group requires such additional time to properly prepare its application for

fees and costs. This motion is made in good faith and not for the purpose of delay; and

Case 1:03-cv-01973-PSF-MJW

Document 188

Filed 11/23/2005

Page 2 of 4

4.

Pursuant to D.C.COLO.LCivR 7.1(A), counsel for Walker Group conferred with

counsel for Mr. Knutson who has indicated Defendants' consent to this Motion.

WHEREFORE, Plaintiff Walker Group, Inc. respectfully prays that the Court enter an Order extending by seven (7) days the time within which it is required to file its application for attorneys' fees and costs.

This the 23rd day of November, 2005.

s/ Richard S. Gottlieb Richard S. Gottlieb Laura A. Greer Kilpatrick Stockton LLP 1001 West Fourth Street Winston-Salem, North Carolina 27101-2400 Telephone: (336) 607-7300 Joshua Maximon, Esq. The Maximon Law Firm, LLC 12202 Airport Way, Suite 170 Broomfield, Colorado 80021 Telephone: (303) 991-3344 Attorneys for Plaintiff Walker Group, Inc.
02560-207219 9045362.1

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Case 1:03-cv-01973-PSF-MJW

Document 188

Filed 11/23/2005

Page 3 of 4

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on November 23, 2005, I electronically filed the foregoing PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following email addresses: [email protected] [email protected], and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participants by first class mail addressed as follows: none.

s/ Richard S. Gottlieb Richard S. Gottlieb Attorney for Plaintiff Walker Group, Inc. Kilpatrick Stockton LLP 1001 West Fourth Street Winston-Salem, North Carolina 27101-2400 Telephone: (336) 607-7300 [email protected]
02560-207219 9045362.1

Case 1:03-cv-01973-PSF-MJW

Document 188

Filed 11/23/2005

Page 4 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 03-CV-1973-PSF-MJW (Consolidated with 04-CV-02112-PSF-MJW) THE WALKER GROUP, INC., Plaintiff, v. FIRST LAYER COMMUNICATIONS, INC. and J.E.H. KNUTSON, Defendants.

ORDER [proposed] Upon Motion of Plaintiff, Walker Group, Inc., pursuant to Rule 6 of the Federal Rules of Civil Procedure, for an extension of time of seven (7) days within which it is required to file its application for attorneys' fees and costs; for good cause shown, IT IS ORDERED that Plaintiff, Walker Group, Inc., shall have an extension of time through and including December 5, 2005 within which to serve and file its application for attorneys' fees and costs. This the ____ day of __________, 2005.

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02560-207219 9045362.1